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10 u 12 1B 14 15 16 18 19 20 21 2 23 24 ANDREW WEISSMANN Chief ALBERT B. STIEGLITZ, JR Assistant Chief MELISSA AOYAGI Trial Attomey Criminal Division, Fraud Section United States Department of Justice 1400 New York Avenue, NW Washington, DC 20530 (202) 514-4313 DANIEL G. BOGDEN United States Attomey District of Nevada STEVEN W. MYHRE First Assistant United States Attorney District of Nevada 333 Las Vegas Blvd., South, Suite 5000 Las Vegas, NV 89131 (702) 388-6298 FILED. RECEVED ENTERED, SERVED ON : (COUNSEL7PARTIES OF RECORD JUL - 8 205 "CLERK Us DISTRICT COURT py, _DStR OF NEVADA DEPUTY UNITED STATES DISTRICT COURT DISTRICT OF NEVADA UNITED STATES OF AMERICA, Plaintiff, EDWIN FUJINAGA, JUNZO SUZUKI, and PAUL SUZUKI, Defendants. ) ) d ) ) ) ) ) ) ) ) 2 ) ) ) ) ) ) ) ) ) ) ) ) ) ) CRIMINAL INDICTMENT aso ALL VIOLATIONS: Title 18, United States Code, Section 1341— Mail Fraud (Counts One through Eight) (as to all defendants); Title 18, United States Code, Section 1343— Wire Fraud (Counts Nine through Seventeen) (as to all defendants); Title 18, United States Code, Section 1957— Engaging in Money Transactions in Property Derived from Specified Unlawful Activity (Counts Bighteen through Twenty) (as to defendant FUIINAGA); Title 18, United States Code, Section 2— Aiding and Abetting (Counts One through ‘Twenty as to defendant FUJINAGA, Counis One through Seventeen as to defendants JUNZO SUZUKI and PAUL SUZUKI) 13 14 15 16 WwW 19 20 ai 22 23 24 ‘The Grand Jury Charges that at all times relevant to the Indictment: BACKGROUND 1. Defendant Edwin FUSINAGA was a United States citizen, residing in Las Vegas, |Nevada. 4, Defendant Junzo SUZUKI (“J. SUZUKI") was a Japanese citizen, residing in Tokyo, Japan. 3, Defendant Paul SUZUKI (“P. SUZUKI") was a Japanese and United States citizen, residing in Tokyo, Japan. 4, MRI International Inc. (“MRI”) was a Nevada Limited Liability Corporation located and operated in Las Vegas, Nevada. Defendant FUJINAGA owned and controlled MRI as its President and CEO. MRI operated a Service Center located in Tokyo, Japan. Defendant SUZUKI was at various times MRI’s Executive Vice President (Asia Pacific), and Defendant P. SUZUKI was at various times General Manager of MRI’s Japan operations. ‘THE SCHEME AND ARTIFICE TO DEFRAUD 5. From at least 2009 and continuing until at least in or about April 2013, FUJINAGA, J. SUZUKI and P. SUZUKI, and others known and unknown to the Grand Jury, aided and abetted by each other, made, and caused to be made, numerous material misrepresentations and omissions designed to fraudulently induce investors to transmit money fo MRI. 6. As part of the scheme and artifice, the defendants represented, among other things, that MRI was engaged in the business of purchasing medical accounts receivable 10 u 12 B 14 15 16 7 18 19 20 21 22 23 24 MARS"), that is, debts owed by recipients of medical services or products to the individuals or entities that provided those services. MRI purported to purchase the accounts from providers at & discounted rate and then collect on the accounts from the patients owing money. MRI's profit from this activity, according to the defendants, was generated from the difference between the price at which MRI purchased the MARS and the amount MRI collected on them due to MRI’s purportedly superior collections capability. 7. Asa further part of the scheme and artifice, the defendants, and others working with them, solicited investments in MRI by offering Certificates of Investment (hereinafter “

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